Project report on

Politics around Article 356 of the

Constitution Of India

Submitted to:

Dr. Avinash Samal

Faculty: Political Science

Submitted by:

Shubhankar Johari

Semester III

Roll no. 191

HIDAYATULLAH NATIONAL LAW UNIVERSITY

NEW RAIPUR - 493661 (C.G.)

Contents

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1. Acknowlegements..
.3
2. Objectives.
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3. Research methodology.
..4
4. Introduction.
..5
5. The Bommai Judgement...
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6. What will the Judiciary do ..
..7
7. Conclusion.
.20
8.
References
.22

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 Acknowledgements
With a deep sense of gratitude, I acknowledge the help of all those people who have made the
completion of this project possible. I would like to thank my Political Science teacher
Dr.Avinash Samal for his help and guidance and also for putting his faith in me by giving me
such a topic to work on. Sir, thanks for the opportunity which helped me to grow.

My gratitude also goes out to the staff and administration of HNLU for the infrastructure in the
form of our library and IT Lab that was a source of great help for the completion of this project.

Shubhankar Johari

Batch XIV

Section C

Roll No. 191

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 OBJECTIVES

To know about Article 356 of the Constitution of India

To know about the politics around Article 356
To know about the stance of the Judiciary
To know the role it has played in Politics of India

RESEARCH METHODOLOGY
This study has been carried out in a descriptive and analytical manner. Secondary and published
documented data has been collected through various sources and analyzed accordingly. Many of the
available literature and studies have also been consulted and reviewed to make the study more objective.
No field work has been carried out in the development of this work.

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 Introduction

Bringing down a state government in todays India is not the simple job of making a ruling party
lose its majority on the floor of the house. The steps have to be carefully orchestrated and often
demand acquiescence from, if not the willing concurrence of, various constitutional
functionaries.

The speaker of the house, who conducts the legislature and has the power to disqualify members
of the assembly, is probably the most important player. If his tribunal disqualifies an MLA for
defection, or even suspends his membership, the orders can only be set aside by a high court or
the Supreme Court.

It also helps to have the ruling party at the Centre, and the governor of the state on your side. The
governors discretion plays a huge role when he calls upon an incumbent chief minister to prove
his majority on the floor of the house. Granting a few extra days to a beleaguered chief minister,
or denying them that can often make the difference between a motion of no confidence being
won or lost. The governor is also charged with ensuring that there is no breakdown of the
constitutional machinery in the state. If at any point he arrives at such a determination and
reports it to the Centre, the Centre can intervene, impose Presidents rule and dismiss the elected
government.

This year we saw this scenario play out twice first in Arunachal Pradesh and then in
Uttarakhand. To this end, Congress dissidents were encouraged to revolt against sitting chief
ministers and to attempt to bring down entrenched governments to minorities within the
legislative assemblies. Even if dissident MLAs numbered less than two-thirds of the strength of
the party in the legislature, they were being insured against the possibility of disqualification.
Defecting MLAs were being supported in court challenges against disqualification, but their
biggest insurance was that the central government was on their side.

BJP leader Kailash Vijayvargiya already foresees similar situations in Manipur and Himachal
Pradesh. Some others talk of extending this to Karnataka as well. The vision of a Congress-

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mukt Bharat, with the party being thrown out of power at the Centre and all states, is a
consummation that the BJP seems to devoutly wish for and work towards. The Congress is
playing a desperate holding action. No state government is being given up without a fight in the
courts and the media. The Congress probably calculates that keeping the BJP occupied in a big
fight in the smaller states is better than taking it on in battle in the bigger and more crucial states.
The only conclusion that an observer can draw is that Indias quasi-federal Constitution is being
operated in a unitary manner with an extreme bias towards the Centre.

A HISTORICAL PERSPECTIVE

But this was not the intention of the founding fathers. On August 4, 1949, towards the end of the
debate on the Centres power to impose Presidents rule in the states, B. R. Ambedkar reassured
the Constituent Assembly:

In regard to the general debate which has taken place in which it has been suggested that these
articles are liable to be abused, I may say that I do not altogether deny that there is a possibility
of these articles being abused or employed for political purposes. But that objection applies to
every part of the Constitution which gives power to the Centre to override the Provinces. In fact I
share the sentiments expressed by my honourable Friend Mr. Gupte yesterday that the proper
thing we ought to expect is that such articles will never be called into operation and that they
would remain a dead letter. If at all they are brought into operation, I hope the President, who is
endowed with these powers, will take proper precautions before actually suspending the
administration of the provinces. I hope the first thing he will do would be to issue a mere
warning to a province that has erred, that things were not happening, in the way in which they
were intended to happen in the Constitution. If that warning fails, the second thing for him to do
will be to order an election allowing the people of the province to settle matters by themselves. It
is only when these two remedies fail that he would resort to this article. It is only in those
circumstances he would resort to this article. I do not think we could then say that these articles
were imported in vain or that the President had acted wantonly.

Despite Ambedkars remonstrations, it became clear to independent India that it was not a true
federation of independent states that had voluntarily acceded into a union. The central

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governments power to override the states, far from being a dead letter, became a heavy hand,
casting a long shadow on centre-state relations.

In March 1953, the countrys first non-Congress government, headed by Gian Singh Rarewala in
the Patiala and East Punjab States Union (PEPSU) was dismissed, leading to a Congress victory
in the elections that followed. In 1957, Kerala saw the worlds first elected communist
government coming into power. A series of progressive measures, opposed by the Catholic
Church in Kerala, as well as American pressure engineered by the CIA, made the work of the
government difficult. In 1959, the then Congress President Indira Gandhi, convinced Prime
Minister Jawaharlal Nehru that E.M.S. Namboodripads government deserved to be dismissed
and Presidents rule should be imposed.

After the Emergency ended in 1977, the first non-Congress government at the Centre, headed by
the Janata Party, dismissed state governments headed by Congress chief ministers and dissolved
the assemblies on the ground that they had lost the peoples mandate. The matter was carried to
the Supreme Court in the State of Rajasthan v. Union of India. A seven-judge bench dismissed
the petition on several preliminary grounds, including its refusal to get into the thicket of
political questions. Some judges even held that presidential satisfaction in invoking Article 356
of the Constitution was not justiciable. Gandhis return to the Centre in 1980 saw her return the
favour by dismissing Janata Party state governments. This action went unchallenged in the courts
in the wake of the Rajasthan judgment.

The invocation of Presidents rule to facilitate or to recover from political horse-trading

continued through the 1980s. Notable examples include Jammu and Kashmir, where the Farooq
Abdullah government was replaced with his brother-in-law G.M. Shahs ragtag battalion, aided
by Governor Jagmohan. In Andhra Pradesh, Governor Ram Lal was used to dismiss the N.T.
Rama Rao government. That episode saw NTR packing off his legislators to Karnataka, which
was ruled by Ramakrishna Hegde of the Janata Party and subsequently parading them before the
president. The practice of the seclusion and transport of MLAs to prevent their defections owes
much to this particular incident.

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In 1985, a constitutional amendment made retail floor-crossing grounds for disqualification for
membership of parliament or state assemblies. The Supreme Court in Kihoto Hollohan v.
Zachillhu and Others ruled that the speakers decisions on disqualification were subject to
judicial review. The result was that defection became a game of footloose legislators, ambitious
leaders-in-waiting and grim court battles. The success of a political operation to topple a sitting
government became dependent on speakers cooperating and courts staying away.

THE BOMMAI JUDGEMENT

The destruction of the Babri Masjid saw Prime Minister P.V. Narasimha Raos government
dismiss four state governments lead by the BJP. In 1994, the challenge to this dismissal and
earlier impositions of Presidents rule came to be decided by a nine-judge bench in the S.R.
Bommai v. Union of India case.

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The judgment held that the presidents satisfaction in the invocation of Article 356 could be
inquired into by the courts. It upheld the dismissal of the BJP governments to protect secularism,
which is part of the Constitutions basic structure. It held that the president was required to act on
objective material, and that Article 356 could only be resorted to when there was a breakdown of
constitutional machinery, as distinguished from an ordinary breakdown of law and order.

The court also held that in no case should a state assembly be dissolved without parliament
approving the proclamation, and that a test of numerical strength could only be conducted on the
floor of the assembly and not outside it. Relying on a Pakistani Supreme Court decision in the
Muhammed Sharif case, the judgment ruled that an improperly dismissed government could be
restored to office. Thus, during Raos minority government, citizens saw the Supreme Court
becoming a strong bulwark of Constitutional right and propriety.

The first major impact of the Bommai judgment was felt in 1997, when President K. R.
Narayanan returned the United Front governments recommendation to impose Presidents rule
in Uttar Pradesh. A year later, he again returned a recommendation by Prime Minister Atal
Behari Vajpayees BJP government to impose Presidents rule in Bihar. Narayanans minute
against the Bihar recommendation recorded that the condition precedent for the invocation
of Article 356, viz. that there has been failure of the Constitutional machinery in the state, has not
been adequately made out by the Governor. Secondly, it held, it would be imprudent to take
action under Article 356 in Bihar when preliminary steps such as warning, directives and
eliciting explanation from the state have not been taken by the Union. Thirdly, it said, the
fact that the government headed by Shrimati Rabri Devi enjoys majority support in the
legislative assembly has to be borne in mind as per the Sarkaria (Commission) passage cited in
the Bommai judgement.

The doctrine in Bommai came to be applied again by the Supreme Court in the Bihar case
of Rameshwar Prasad & Ors v. Union of India. In 2005, Governor Buta Singh, after an
inconclusive election, recommended the dissolution of the state assembly, without it being
convened even once. The court struck down the imposition as unconstitutional but refused to
restore the assembly because another election had already been ordered. Singh resigned in the
wake of the judgment.

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Since the Bommai judgment of 1994 and Narayanans interventions of 1997 and 1998, instances
of the wanton imposition of Presidents rule dwindled considerably. It must also be mentioned
that the nineties saw governments with no absolute parliamentary majorities for any one party.
Constitutional norms began to be set and enforced by organs of the state that were not
particularly overwhelmed by a strong political leadership with dominant majorities.

WHAT WILL THE JUDICIARY DO

The onset of a one party majority government at the centre has seen the testing of the set
dynamics of the past decades. It is only in recent times that a spurt of efforts to impose Article
356 has been seen and more instances seem to be on the horizon. This year, the Supreme Court
has heard the challenge to the imposition of Article 356 in Arunachal Pradesh for nearly a month.
Here, a fresh alignment of forces may have overtaken any relief that was possible at the hands of
the court. The Uttarakhand case too, is soon likely to reach the Supreme Court.

The doctrines and parameters of judicial review have already been set out in the Bommai and
Rameshwar Prasad cases. The question is of the willingness of the judiciary to cut through the
political thicket in time to be of consequence to the political process. In the absence of a strong
and effective judicial interdict, a majority government may well be tempted to brave adverse
comments in the distant future, if there is the immediate gain of adding another outpost to the

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empire. The question really is whether the judiciary today is willing to restate and apply settled
doctrine in the changed climate of the Modi era. The coming months should see an answer for
our interesting times.

The use of Article 356 to dismiss a state government and impose presidents rule is now
regulated by the landmark judgment of the Supreme Court in the Bommai case, which laid down
two propositions: first, the proclamation issued by the president under Article 356 is subject to
judicial review, and second, the question of majority should be decided on the floor of the
legislature and not in the Raj Bhavan. It also listed out the situations under which presidents rule
should not be imposed. However, this judgment did not enumerate the grounds on which Article
356 can be invoked. Article 356 says that if the president is satisfied that a situation has arisen in
which the government of the state cannot be carried on in accordance with the provisions of the
constitution, the president will assume to himself the functions of the state government. This in
simple language means the imposition of Central rule.

The words the government of the state cannot be carried on in accordance with the provisions of
the constitution essentially mean the provisions relating to the administration of the state, and
not any and every provision in the constitution. There are some core provisions that are central to
administering a state. For example, the provision that requires the council of ministers to be
collectively responsible to the legislature means that if the government loses its majority in the
house and no alternative is possible, then presidents rule becomes unavoidable. Secondly, if a
state government cannot get the budget passed, it loses its constitutional right to administer the
state. Thirdly, if there is large-scale internal disturbance that cannot be controlled by the state
government, intervention by the president will become necessary. Fourthly, if a state fails to
comply with any direction given by the Centre in exercise of its executive powers, presidents
rule can be imposed.

There may be many other situations causing the breakdown of the constitutional machinery in a
state necessitating presidential intervention, but the situations mentioned are the most crucial to
the administration of the state. The imposition of presidents rule on the ground of non-
compliance with the Union governments directions has perhaps not been done so far.

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Now let us try to understand the Uttarakhand situation, which was needlessly complicated by the
Centres untimely intervention.

It was perfectly legitimate for Governor K. K. Paul to ask former chief minister Harish Rawat to
prove his majority in the assembly on March 28, after nine Congress members broke away from
the party. The governor acted perfectly in accordance with the directions of the Supreme Court in
the Bommai case.

But a day before the floor test was to be held, the Union cabinet held an emergency meeting and
advised President Pranab Mukherjee to impose Central rule in the state. An unprecedented move,
it showed complete disregard of the law laid down by the Supreme Court. Presidents rule should
have become an option only after the floor test.

What triggered the emergency meeting was the governors report after a sting operation showed
Rawat offering money to MLAs for their support. In a fit of great moral outrage, the Centre
decided to act quickly. Mukherjee was said to have signed the proclamation when he was shown
the video, which was certified as genuine by a forensic lab. This means that presidents rule was
imposed on the ground that the chief minister had attempted to bribe some legislators for their
support.

This reason is alien to Article 356. At best it could be the basis of a petition against the chief
minister under the Prevention of Corruption Act, but it certainly does not justify the imposition
of presidents rule.

Failure to pass Appropriation Bill as grounds for Central rule

The BJP brought up another reason in support of the imposition of presidents rule. It was
claimed that the state government could not get the Appropriation Bill passed and this led to a
situation in which the government could not function in accordance with the constitution. But
this argument requires a closer examination.

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According to the speakers statement, the Appropriation Bill was passed by voice vote on March
18. As per the procedure and practice, this bill is passed by voice vote and no division (recording
of vote) is held or allowed, as such a bill is used to authorise the government to appropriate the
money from a consolidated fund that has just been voted by the assembly. Once the house has
voted the grants, the bill to authorise the appropriation of the same grants cannot be opposed.
Article 204 bars even amendments to such a bill. Given that the Uttarakhand assembly had voted
the grants, any demand for a division of vote is against the constitution and well-established
parliamentary practices. Thus, the imposition of presidents rule on the ground that the
Appropriation Bill could not be passed is unconstitutional.

Who decides if an Appropriation Bill has been passed? It is only the speaker, and the
Constitution does not recognise any other authority to decide on this question.

Article 212 provides house proceedings immunity from being called into question before a court
of law. Even when the speaker refuses to order a division of vote when it is demanded for other
bills, it could be considered a procedural irregularity, which the court will not look into.

This position was settled in 1952 in the State of Bihar v. Kameshwar Singh case. In this case, a
bill passed by the Bihar assembly was challenged inter alia on the grounds that the speaker did
not formally put a motion before the assembly to pass the bill, and thus it was contended that the
bill had not been passed. The Supreme Court relied on the speakers endorsement of the bill to
signify that it had, in fact, been passed, going on to say that it was a procedural irregularity and
Article 212 bars the court from looking into it.

This immunity has been provided to the proceedings of a legislative house because otherwise
there may be frequent challenges in the courts, and the house will be unable to function with
absolute freedom which is its privilege.

An unconstitutional imposition

But presidents rule cannot be imposed under Article 356 due to a procedural irregularity in the
proceedings of the assembly. To presume that the government was in a minority, and thus
unconstitutional, when the Appropriation Bill was put before the house on March 18 makes no

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sense because the grants were passed just before that by the same house. Moreover, the question
of majority was to be decided on March 28 as per the governors direction. Until such a vote is
held, the government is presumed to have the confidence of the house.

Thus, the imposition of presidents rule in Uttarakhand is without constitutional basis. The Union
government followed it up with the prorogation of parliament and the promulgation of an
ordinance to appropriate money from the consolidated fund of the state. Even this ordinance is an
admission of the fact that the state assembly had voted the grants, as otherwise the Appropriation
Bill could not have been brought through an ordinance. As a matter of fact, the Appropriation
Bill had already been passed by the assembly. So prorogation against the rules of both houses of
parliament and the promulgation of an ordinance were totally unnecessary. It is hoped that the
high court will be able to untangle this mess.

The Uttarakhand saga is an interesting case study for students of the Constitution. It has played
out like a 15th century morality play, and the politics of it is too clichd and hypocritical. It has
mocked the integrity of well-established institutions. And it is far too disastrous for Indian
democracy.

It is a well-known fact that Article 356 of the Constitution has been used, misused and abused by
the powers at the Centre mostly Congress party to unsettle the non-Congress governments in
the state on very flimsy grounds.
Arunachal Pradesh is not the only isolated case in point. A cursory look at the history of such
events would prove this point beyond doubt.

As per the provisions of Article 356 Presidents Rule can be imposed in a state in case of failure
of democratically elected government, mainly due to lack of majority. The state is brought under
Central Rule, the Governor being the representative of the President.

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When Presidents Rule is imposed the Chief Minister and his Council of Ministers stands
dissolved and the Governor becomes the de jure constitutional head. The state assembly is either
put in the suspended animation so that alternatives for forming popular government could be
explored or the House is dissolved and fresh elections are conducted.
This provision of imposing Central Rule has its origin in the Government of India Act 1935 that
formed the bedrock of our Constitution and its provisions. The then British Occupation
Government of India conceded right to government to provincial bodies but inserted a provision
of retreat to the Centre to keep an iron grip over the native politicians ruling these provincial
councils.
But, of course, this was colonial rule and there were limits. One check was Section 93 of the
Government of India Act which allowed a provincial governor appointed by the British Raj in
Delhi to assume the powers of a provincial government if the administration cannot be carried
on with the provisions of the act. This was the first avatar of the current Article 356.

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The Congress which had won the elections in eight of the 11 provinces at the time protested
strongly against the undemocratic provision of Section 93. It demanded that the British Viceroy
give an assurance that the governor would not interfere with the working of the elected
provincial governments. Linlithgow, the Viceroy, did and only then did the Congress assume
office.

After Independence the Congress replaced the British Rule with a difference that Section 93
became Article 356 in our new Constitution keeping the provisions intact and unchanged.
This Article makes India a unique nation amongst federal democracies to have provision to
dismiss an elected popular government and the successive governments in Delhi have used this
Article liberally. Since 1950, the year in which India accepted the Constitution and proclaimed
itself a Republic, there have been 113 instances of unsettling the democratically elected
governments in the states.
Ignoring the directive principle that states Article 356 is only to be used in case of failure of
constitutional machinery, the governments at the Centre used, misused and abused it umpteen
times obviously to guard the political interests of the ruling party in Delhi. As JR Siwach wrote
in 1977, the main consideration in case of Article 356 has always been the interests of the
Congress Party in the Centre.
Ironically, it was Nehru, one of the framers of the Constitution and First Prime Minister of India
who misused the Article 356 in dismissing the democratically elected government of Punjab
headed by Chief Minister Gopichand Bhargava.
Moreover, in what would become a regular practice, the governors letter asking for Presidents
rule originated not with the governor but with the Centre itself. Historian Granville Austin writes
that in this case, the Congress had blended its interests with questionable national needs to take
over a state government. In 1954, the Andhra states government was dissolved because the
Centre feared a communist regime taking power.
In 1959, Nehru dismissed the Communist government in Kerala even as the Congress was
involved in a bitter political battle in the state. How did the Governor justify dismissing an
elected government which still enjoyed the confidence of the house? It is not necessary that a no
confidence motion be passed, the Governor said. I am convinced that the government has lost
the support of the majority of the people.

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Matters kept on deteriorating until reaching a climax in 1970s, as instability at the Centre meant
Delhi would often dismiss elected governments in order to further the narrowest of politic
interests.

In 1977 and 1980, the Janata Party and Congress dismissed state governments not controlled by
their party on a mass scale, not even bothering to pretend that they were working under the
constitution.
In 1983 the Sarkaria Commission by the central government of India to examine the relationship
and balance of power between state and central governments in the country and suggest changes
within the framework of Constitution of India.

It recommended that Article 356 only be used in extreme cases, it gave 247 recommendations but
none were implemented. Any real curb on the powers of the Centre would have to come from the
judiciary.

1. Bommai v. Union of India case in 1991 was a landmark judgment of the Supreme Court
of India, where the Court discussed at length provisions of Article 356 of the Constitution of
India and related issues.

This case had huge impact on Centre-State Relations. The misuse of Article 356, popularly
known as Presidents Rule, to impose central authority on states, was stopped after this
judgment.

The Supreme Court laid down strict guidelines on how a state government is to be dismissed,
making it mandatory for a no-confidence motion to be passed in the house. The assessment of
the strength of the Ministry is not a matter of private opinion of any individual be he the
Governor or the President, the judgement read. It also made the use of Article 356 subject to
review by the courts, overturning the earlier convention where the government of India was
supreme.

Dr. Babasaheb Ambedkar, Chairman of the Drafting Committee of the Constitution of India,
referred to Article 356 as a dead letter of the Constitution. In the constituent assembly debate it
was suggested that Article 356 is liable to be abused for political gains.

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Dr. Ambedkar replied,
I share the sentiments that such articles will never be called into operation and they would
remain a dead letter. If at all they are brought into operation, I hope the President, who is
endowed with these powers, will take proper precautions before actually suspending the
administration of the provinces. I hope the first thing he will do would be to issue a mere
warning to a province that has erred, that things were not happening in the way in which they
were intended to happen in the Constitution. If that warning fails, the second thing for him to do
will be to order an election allowing the people of the province to settle matters by themselves. It
is only when these two remedies fail that he would resort to this article.
But this was never the case and before the judgement in Bommai case, Article 356 has been
repeatedly abused to dismiss the State Governments controlled by a political party opposed to
ruling party at centre.
Former Prime Minister Indira Gandhi tops the list of Prime Ministers to impose Central Rule in
states. She did so on 50 occasions! Morarji Desai invoked this Article for 16 times, Manmohan
Singh for 12 times, P V Narasimha Rao for 11 times, Jawaharlal Nehru used it for 8 times, Rajiv
Gandhi 6 times, Atal Bihari Vajpayee and Chandrasekhar five times each while Narendra Modi
in his brief tenure of two years imposed Presidents Rule three times.

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 CONCLUSION
This Article provides for the imposition of the Presidents rule when there is failure of
constitutional machinery in the state. The ambiguity of expression if a situation has arisen in
which the government of the state cannot be carried on in accordance with the provision of the
Constitution had led to the Articles persistent misuse by all governments at the Centre. Nearly,
after the seven decades of independence Indian federalism has passed through several stages and
the relationship between the centre and the states has also been volatile and irresolute. Though,
the Constitution attempts to divide the power in a clear cut manner and seeks to reduce the
chances of conflicts between the centre and the states, the nature of Indian federalism are not
only determined by these provisions.

There are several other institutional arrangements which play a crucial role in determining the
shape and direction of Indian federal system such as office of president, governor, judiciary and
role of political parties and some other constitutional provisions. Indian constitution does not
originally make any specific mention of political parties like the U.S, and diverse and complex
nature of Indian federal system is not favorable for the two party systems.

In the early years of independence Congress was a single dominant party at centre as well as in
almost all the states. Indian federalism working rather smoothly, solving the disputes as inter
party conflicts, but the scenario changed after the 1967 elections, when congress lost its control
in almost half of the states, and the cases of misuse of article 356 began to emerge. Operation of
the multi-party system at the two levels of the government put the provisions of the federalism to
test. Initially, the central government presented its positive and cooperative gesture towards these
governments, but in practice the congress government did not showed cooperation with these
opposition governments. The non congress ministries in Haryana, UP, and West Bengal were
dismissed even when they enjoyed a majority in their respective state legislatures.

After independence there have been several disgraced examples of this execrable politics.
Specially, in 1977 when the Janata government suspended congress governments in nine states
on the ground that these governments had lost legitimacy and faith of the people as was Congress
was defeated in general election held after emergency. In 1979, after the disintegration of the
Janata government congress backed to the power and suspended the governments installed by the

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Janata party in the same manner. The political history of the suspension of the government shows
that almost all the suspended governments have been from opposition parties holding the
governments of the states. Committees formed on centre State relations also signify Article 356
as a core point of tension between centre and the states. The supreme court of India in the case of
S.R. Bommai v. Union of India asserted that the power of proclamation under Article 356 must
be used with circumspection and in a non partisan manner.

In proclamation of Article 356 the role of governor has also been an issue of debate. At the time
of drafting the constitution the matter of selection of the governor was also discussed by the
representatives. They made a provision of appointed governor rather than elected one to ignore
the problems of overlapping the authority and assure a smooth and amiable functioning of the
government of the states. But the cases shows that in the political crisis the role of governor has
been as an agent of centre, a persuader of constitutional breakdown and never been free from
political biasness. Periodically, they have proved their political fidelity towards their patron
political parties over the allegiance and responsibilities of constitutional office. It is perceived
that after the end of one party dominance and in the era of coalition government the dimension of
Indian federalism has been changed from a conflict era to a more cooperative federal system. But
the recent incident has proved that the Indian political system has to cut across a long route of
malicious politics, misuse of constitutional provisions and holding the dignity and impartiality of
the gubernatorial office, towards a cooperative federalism.

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 References

www.scribd.com
http://www.informit.com
www.en.wikipedia.org
www.indianexpress.com
www.firstpost.com

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